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The ECGT: what Irish small businesses need to know about EU environmental claims rules

March 2026 EU Regulation

The EU Green Claims Directive got a lot of attention — and then was withdrawn. But that does not mean the issue has gone away. A different directive is already law and applies from September 2026. Here is what it means for your business.

A quick bit of context

You have probably seen it everywhere. Products labelled "eco-friendly", "carbon neutral", "green", or "sustainable". For a long time there were no clear rules about what those words actually had to mean.

The EU decided to change that. In 2023, it proposed the Green Claims Directive, which got a lot of attention. Then in June 2025, that proposal was withdrawn, partly because the rules were seen as too burdensome for smaller businesses.

But that does not mean nothing is happening.

The law that is actually coming into force

While the Green Claims Directive grabbed the headlines, another directive was quietly moving forward. The Empowering Consumers for the Green Transition Directive (ECGT, Directive 2024/825) is already adopted, already law, and will apply across the EU from 27 September 2026. Ireland must transpose it by March 2026. In Ireland, it will be enforced by the Competition and Consumer Protection Commission (CCPC).

This is not a proposal. This is law.

What is banned from September 2026?

The directive adds a "blacklist" of practices that are automatically unfair. No need to prove a consumer was misled — the act itself is the violation. Here is what is now banned:

  • Generic claims like "eco-friendly", "green", "natural", or "sustainable" without proof of recognised environmental performance.
  • "Carbon neutral", "net zero", or "reduced climate impact" claims based on offsetting rather than actual emission reductions.
  • Environmental claims about your whole product or business when they only apply to one part of it.
  • Self-made sustainability labels or green logos not backed by an official third-party certification scheme.
  • Future green commitments such as "carbon neutral by 2030" without a clear, verified, publicly available plan.

Does it apply to small and micro businesses?

Yes. Unlike some larger EU regulations, there is no exemption for small or micro businesses under the ECGT. If you sell to consumers, you must comply. The rules apply to any business-to-consumer claim, on your website, social media, packaging, or anywhere else a customer might see it.

What to do now

You have time, but not much. Here is where to start:

  1. Audit your claims. Go through your website, social media, and packaging. List every environmental claim you make, however small.
  2. Replace vague with specific. "Our packaging is eco-friendly" becomes "Our packaging is made from 70% recycled cardboard." The action is not to delete, it is to sharpen.
  3. Check your labels. If you use any green logo or badge, make sure it comes from a recognised certification body. If it does not, find one that applies to what you actually do.
  4. Be careful with carbon claims. Anything involving offsets or neutrality needs to reflect your actual operations, not a scheme you contributed to.
  5. Document what you do. The burden of proof sits with you as the trader. Start building a simple record of the evidence behind each claim you make.
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